
Charity Services & Pro-Bono Psychotherapy Agreement
Charity Services & Pro-Bono Summary
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Pro-bono services and sliding fee scales are offered based on Medicaid status and/or severe financial hardship (e.g., unemployment, medical necessity), subject to availability, with a written application and flexible documentation (e.g., proof of income loss, utility bills, pay stubs). These services comply with:
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Section 1557 of the Affordable Care Act (42 U.S.C. § 18116), ensuring no discrimination based on race, color, national origin, sex, age, or disability;
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The No Surprises Act, providing Good Faith Estimates and clear explanation of insurances accepted, payment arrangement expectations, payment waiver expectations, refund policies, collection efforts, and timelines for arbitration efforts due to payment-related concerns.
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Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d), preventing discrimination based on race, color, or national origin;
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Age Discrimination Act of 1975 (42 U.S.C. §§ 6101-6107), ensuring access regardless of age;
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Americans with Disabilities Act (42 U.S.C. §§ 12101 et seq.), providing reasonable accommodations;
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Ohio Revised Code § 4757, upholding licensing and ethical nondiscrimination standards in sliding fee scale and pro-bono offering agreements, GFE transparency.
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Federal law provides that individuals eligible for medical assistance may obtain services from any qualified person who undertakes to provide them (42 U.S.C. § 1396a(a)(23)). This practice operates on a cash-pay and voluntary charity (pro-bono) basis outside the Medicaid program. No services are billed to Medicaid, and no claim is submitted on behalf of any client.
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Clients retain the freedom to choose their provider consistent with federal principles of patient choice. Pro-bono services are offered in accordance with this practice’s faith-based mission to serve individuals regardless of income, with no expectation of payment from the client. Consistent with the nature of voluntary charity care and the requirement under the Social Security Act that states use reasonable standards for determining income and resources (§ 1902(a)(17)), such services are generally not treated as income or a countable resource for Medicaid eligibility purposes.
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Free or pro bono psychotherapy and counseling services, including faith-based counseling, may be offered by the Provider to individuals who voluntarily elect to receive them. Such services are offered independently and without any requirement, condition, or connection to the provision of any other item or service for which payment may be made, in whole or in part, under Medicaid, or any other federal health care program.
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Under 42 C.F.R. § 1003.110, certain offers or transfers of items or services for free or less than fair market value are generally excluded from the definition of “remuneration” when they are not tied to the provision of other items or services reimbursed in whole or in part by a Federal health care program. The Company structures its voluntary pro-bono psychotherapy as standalone charity care, independent of any Federal or Company reimbursable service. The Company has structured its voluntary charity-care program with the intent of complying with applicable federal and state laws.
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To maintain clear clinical boundaries and ensure that voluntary pro-bono psychotherapy remains independent of any commercial services (Service Exclusivity), clients receiving pro-bono psychotherapy under this Agreement shall not concurrently receive Life Coaching or Athletic Coaching Wellness Services from the Company. This separation is intended to prevent dual relationships and to ensure that free clinical care is not used as an inducement or gateway to any paid services.
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Accordingly, the provision of standalone, free clinical counseling services by the Provider as described intends to structure free psychotherapy as standalone charity care, independent of any federally reimbursable service, to avoid inducement concerns.
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We provide clear service distinctions/service exclusivity to clients per federal consumer protection laws (15 U.S.C. §§ 41-58) and dual relationship guidelines (OAC Rule 4757-5-03.)
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The Company makes no representation regarding the Client’s specific Medicaid eligibility status. The Client is encouraged to consult with a benefits specialist or county agency if they have questions about their own eligibility.

